Privacy Policy

Privacy policy

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as "Data") in the course of the provision of our services, as well as our online services and related websites, features and content, the external online presence, such as websites, our social media profile (collectively referred to as the "Online Offering"). With regard to the terminology used, e.g. "Processing" or "Responsible", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Purposes of processing personal data

Terms

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter the "data subject"); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

"Processing" means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.

"Pseudonymisation" means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.

"Profiling" means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.

The “responsible party” is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data.

The "processor" is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the responsible party.

Relevant legal basis

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i. the EU and the EEC, unless the legal basis in the data protection declaration is mentioned:
The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR;
The legal basis for the processing for the fulfillment of our services and the execution of contractual measures as well as the answer to inquiries is Art. 6 para. 1 lit. b GDPR;
The legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as legal basis.
The legal basis for the processing required to perform a task in the public interest or in the exercise of official authority which has been delegated to the responsible party is Article 6 (1) lit. e GDPR.
The legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR.
The processing of data for purposes other than those to which they have been granted is governed by the provisions of Article 6 (4) GDPR.
The processing of special categories of data (according to Art. 9 (1) GDPR) is governed by the provisions of Art. 9 (2) GDPR.

Security measures

In accordance with legal requirements, we take into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons, appropriate technical and organizational Measures to ensure a level of protection appropriate to the risk.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings.

Collaboration with contract processors, responsible party and third parties

If, in the context of our processing, we disclose data to other persons and companies, transmit them to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (eg if a transmission of the data to third parties, such as to payment service providers, is necessary for the fulfilment of a contract), users have consented to a legal obligation to do so or based on our legitimate interests (eg, when using agents, web hosts, etc.).

If we disclose data to other companies in our group, convey it or otherwise grant access to it, this is done in particular for administrative purposes as a legitimate interest and, moreover, based on a legal basis.

Transfers to third countries

If we process data in a third country (ie outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or in the context of the use of third party services or disclosure, or transfer of data to other persons or companies, this will only happen if it is to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only in the presence of legal requirements. That the processing is e.g. based on specific guarantees, such as the officially recognized level of data protection (for example, the US Privacy Shield) or compliance with officially recognized specific contractual obligations.

Rights of data subjects

You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and copying of the data in accordance with legal requirements.

Accordingly to the statutory provisions you have the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with the statutory provisions you have the right to demand that the relevant data be deleted immediately, or alternatively to demand a restriction of the processing of the data in accordance with the statutory provisions.

You have the right to request that the data relating to you provided to us be obtained in accordance with legal requirements and to request their transmission to other persons responsible.

You also have the right to file a complaint with the competent regulatory authority.

Right of revocation

You have the right to withdraw granted consent with effect for the future.

Right of objection

You may object to the future processing of your data in accordance with legal requirements at any time. The objection may in particular be made against processing for direct marketing purposes.

Cookies and right to object in case of direct mail

"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online shop or a login status are saved. The term "permanent" or "persistent" refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A "third-party cookie" refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, this is called "first-party cookies").

We can use temporary and permanent cookies and clarify this in the context of our privacy policy.

If users do not want cookies stored on their computer, they will be asked to disable the option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general contradiction to the use of cookies used for online marketing purposes can be found in a variety of services, especially in the case of tracking, can be explained via the US website http://www.aboutads.info/choices/ oder die EU-Seite http://www.youronlinechoices.com/ Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all features of this online offer may be used.

Deletion of data

The data processed by us will be deleted or restricted in accordance with legal requirements. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements.

Unless the data is deleted because it is required for other and legitimate purposes, its processing will be restricted. That is, the data is blocked and not processed for other purposes. This applies for example for data that must be kept for commercial or tax reasons.

Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adjust the privacy policy as soon as the changes to the data processing we make require it. We will notify you as soon as the changes require your participation (eg consent) or other individual notification.

Here we process stock data (e.g. customer master data, such as names or addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text inputs, photographs, videos), contract data (e.g. subject matter, term), payment data (e.g. bank account, payment history), usage and metadata (for example in the context of the evaluation and success measurement of marketing measures). In principle, we do not process special categories of personal data, unless these are components of a commissioned processing. Those affected persons or subjects include our customers, prospects and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contract services, billing and our customer service. The legal basis of the processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that are necessary for the establishment and performance of the contractual services and indicate the necessity of their information. Disclosure to external parties will only be made if required by an order. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as with the legal requirements of order processing pursuant to Art. Art. 28 GDPR and process the data for no other purpose than the order.

We delete the data after expiry of legal warranty and comparable obligations. The necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiry (6 years in accordance with § 257 (1) HGB, 10 years in accordance with § 147 (1) AO).In the case of data disclosed to us in the context of an order by the client, we delete the data according to the specifications of the order, in principle after the end of the order.

We process data in the context of administrative tasks and organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of rendering our contractual services. The processing principles are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose and interest in processing lies in administration, financial accounting, office organization, data archiving, that is, tasks that serve to maintain our business, perform our duties and provide our services. The deletion of the data in terms of contractual performance and contractual communication corresponds to the information provided in these processing activities.

We disclose or transmit data to the financial administration, consultants, such as tax accountants or auditors, and other fee agents and payment service providers.

Furthermore, based on our business interests, we store information about suppliers, promoters and other business partners, e.g. for later contact. We generally store this majority of company-related data permanently.

Business analysis and market research

In order to operate our business economically, to be able to recognize market trends, wishes of the contracting parties and users, we analyze the data we have on business transactions, contracts, inquiries, etc. We process stock data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.

The analyses are carried out for the purpose of business analysis, marketing and market research. In doing so, we can take into account the profiles of registered users with details of their services used. The analyses serve us to increase the user-friendliness, the optimization of our offer and the business economics. The analyses are for us alone and will not be disclosed externally unless they are anonymous, aggregated value analyses.

If these analyses or profiles are personal, they will be deleted or anonymised upon termination of the users, otherwise after two years from the conclusion of the contract. Incidentally, the overall business analyzes and general trend provisions are created anonymously if possible.

Contacting

When contacting us (for example, by contact form, e-mail, telephone or via social media) the information of the user to process the contact request and its processing are processed in accordance with. Art. 6 para. 1 lit. b. (in the context of contractual / pre-contractual relationships), Art. 6 para. 1 lit. f. (other requests) GDPR. User’s data can be stored in a Customer Relationship Management System ("CRM System") or comparable request organization.

We delete the requests, if they are no longer required. We check the necessity every two years. Furthermore, the legal archiving obligations apply.

Newsletter

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter "newsletter") only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Incidentally, our newsletter contains information about our services and us.

Double opt-in and logging: Registration for our newsletter is done in a so-called double-opt-in procedure. This means that you will receive an e-mail after logging in to ask for confirmation of your registration. This confirmation is necessary so that nobody can register with third-party e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged.

Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.

The logging of the registration process is based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. Our interest lies in the use of a user-friendly and secure newsletter system, which serves both our business interests and the expectations of the users and also allows us to prove our consent.

Termination / Revocation - You may terminate the receipt of our newsletter at any time, ie. revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may save the submitted email addresses for up to three years based on our legitimate interests before we delete them to provide prior consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.

Newsletter - Mailchimp

The newsletters will be sent by MailChimp, a mail-order service provider of Rocket Science Group, LLC, 675 Ponce De Leon Ave # 5000, Atlanta, GA 30308, USA. The privacy policy of the shipping service provider can be viewed here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection standards (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The shipping service provider is used on the basis of our legitimate interests acc. Art. 6 para. 1 lit. f. GDPR and a contract processing agreement acc. Art. 28 (3) sentence 1 GDPR.

The shipping service provider may use the data of the recipients in pseudonymous form, that is without assignment to a user, to optimize or improve their own services, e.g. for the technical optimization of shipping and the presentation of newsletters or for statistical purposes. However, the shipping service provider does not use the data of our newsletter recipients to address them themselves or to pass the data on to third parties.

Newsletter – Performance Measurement

The newsletters contain a so-called "web-beacon", that is a pixel-sized file that is retrieved from the server when opening the newsletter from our server or from the server of the shipping service provider (if we use a shipping service provider). This call will initially collect technical information, such as information about the browser and your system, as well as your IP address and time of retrieval.

This information is used to improve the technical performance of services based on their specifications or audience and their reading habits, based on their locations (which can be determined using the IP address) or access times. Statistical surveys also include determining if the newsletters will be opened, when they will be opened and which links will be clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our goal nor, if used, that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

A separate revocation of the performance measurement is unfortunately not possible, in this case, the entire newsletter subscription must be terminated.

Hosting and E-Mailing

The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security and technical maintenance services we use to operate this online service.

Collection of access data and log files

We, or our hosting provider, collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR Data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.

Google Tag Manager

Google Tag Manager is a solution that allows us to manage so-called web site tags through one interface (including, for example, Google Analytics and other Google marketing services in our online offering). The tag manager itself (which implements the tags) does not process users' personal data. With regard to the processing of users' personal data, reference is made to the following information about Google's services. Usage Policy: https://www.google.com/intl/de/tagmanager/use-policy.html.

Google Analytics

Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR), we use Google Analytics, a web analytics service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offer by the users are usually transmitted to a Google server in the USA and stored there.

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.

The IP address submitted by the user's browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to its use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

The personal data of users will be deleted or anonymized after 14 months.

Target group formation with Google Analytics

We use Google Analytics to display advertisements displayed within Google and its affiliate advertising services only those users who have shown an interest in our online offering or who have certain characteristics (eg interests in specific topics or products which are determined by the websites visited by them) that we submit to Google (so-called "remarketing" or "Google Analytics audiences"). With Remarketing Audiences, we also want to make sure that our ads meet the potential interest of users.

Online presence in social media

We maintain online presence within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services.

We point out that data of the users can be processed outside the area of the European Union. This may result in risks for the users, for example, to make it harder to enforce user’s rights. With respect to US providers certified under the Privacy Shield, we point out that they are committed to respecting EU privacy standards.

Furthermore, the data of the users are usually processed for market research and advertising purposes. For example, user profiles can be created from the user behavior and resulting user interests. The usage profiles, in turn, may be used to, for example, serve advertisements inside and outside the platforms that are allegedly in the interests of the users. For these purposes, cookies are usually stored on the computers of the users, in which the user behavior and the interests of the users are stored. Furthermore, in the usage profiles, data can also be stored independently of the devices used by the users (in particular if the users are members of the respective platforms and logged in).

The processing of the personal data of users is based on our legitimate interests in an effective information of users and communication with users in accordance with. Art. 6 para. 1 lit. f. GDPR. If the users are asked by the respective providers of the platforms for a consent to the above-described data processing, the legal basis of the processing is Art. 6 para. 1 lit. a., Art. 7 GDPR.

For a detailed description of the respective processing and the possibilities of contradiction (opt-out), we refer to the following linked information of the provider.

Also in the case of requests for information and the assertion of user rights, we point out that these can be claimed most effectively from the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, then you can contact us.

Integration of services and contents of third parties

Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR), we make use of content or services offered by third-party providers in order to provide their content and services, such as videos or fonts (hereafter referred to collectively as "Content").

This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer as well as be linked to such information from other sources.